Jeffrey R. Taylor - Page 4

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          records, and the investigation essentially focused on attempting            
          to re-create the financial transactions of the corporation.  Ms.            
          Taylor, who primarily maintained the financial records, did not             
          cooperate with the investigation, and petitioner's cooperation              
          was limited.  The investigators had to issue summonses to third             
          parties to obtain records.                                                  
               When CID accepts a case, the special agent of CID and the              
          revenue agent of the Internal Revenue Service (Examination                  
          Division) may undertake a joint investigation; the special agent,           
          however, controls the investigation.  Normally the revenue agent            
          continues to investigate the civil aspects, but the revenue agent           
          would have no contact with the taxpayer unless the special agent            
          was present.  The special agent is interested in obtaining                  
          evidence of violations of criminal statutes.  See United States             
          v. Crespo, 281 F. Supp. 928, 931-932 (D. Md. 1968).  On August              
          19, 1991, the Examination Division placed its examination of                
          petitioner's liability in the "Fraud Suspense" category.  At that           
          time the revenue agent prepared a preliminary computation with              
          the understanding that the civil aspects of the case would remain           
          in suspense until the criminal aspects were completed.  While the           
          case was in "Fraud Suspense", it was decided by the District                
          Director that the normal period of limitations for the 1984,                
          1985, 1986, and 1987 tax years would be allowed to expire without           

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